IRAC NORMS

SEMINAR ON BANK BRANCH AUDIT

Organised by: W.I.R.C OF I.C.A.I SATURDAY 19TH MARCH 2011
VIPUL K. CHOKSI, FCA

AGENDA

Objectives RBI Circulars Identification of Account as NPA Exceptions / Clarifications Projects under Implementation Asset Classification and Provisioning Guidelines on Restructuring of Advances Agricultural Debt Waiver Scheme
Vipul K. Choksi, FCA

Objectives
The classification of assets of banks has to be done on the basis of objective criteria, which would ensure a uniform and consistent application of the norms. The provisioning should be made on the basis of the classification of assets based on the period for which the asset has remained non-performing and the availability of security and the realisable value thereof.
Vipul K. Choksi, FCA

RBI Circular Reference

Master Circular dated 1st July 2010 on IRAC Norms. Circular dated 7th October 2010 on restructuring of advances. Circular dated 23rd December 2010 on housing loans by banks .

Vipul K. Choksi, FCA

Asset Type
STANDARD ASSET / PERFORMING ASSET
The account is not non-performing and does not carry more than the normal risk attached to the business.

NON-PERFORMING ASSET (NPA)

The asset ceases to generate income for the bank. Higher risk than normal risk attached to business. Non performing as per various criteria for various types of loans.

Vipul K. Choksi, FCA

Identification of Account as NPA

Loans or Advance Interest and/or installment remains overdue for a period of more than 90 days in respect of a term loan. As per para 2.1.3, an account is classified as NPA only if interest due and charged during any quarter is not serviced fully within 90 days from the end of the quarter. Loans with moratorium for payment of interest . Housing Loan or similar advance to staff.
Vipul K. Choksi, FCA

Exceptions

Identification of Account as NPA ...

Bills Purchased and discounted Agricultural Advances Derivative Transaction Bill remains overdue for a Discounted period of more than 90 days. Interest or installment remains overdue for two crop seasons for short duration crop, one crop season for long duration crop. Overdue receivables representing positive mark to market value of a derivative contract remaining unpaid for a period of 90 days from specified due date. Remains outstanding for more than 90 days in respect of Securitisation transaction.
Vipul K. Choksi, FCA

Liquidity facility

Identification of Account as NPA ...

Cash Credit / Overdrafts Account remains out of order

The account is treated as out of order if :

Outstanding Balance remains continuously in excess of sanctioned limit/drawing power (for how many days?) or No credit continuously for 90 days as on the date of Balance Sheet or Credits in the account are not sufficient to cover interest debited during the same period.

Vipul K. Choksi, FCA

Exceptions / Clarifications
Temporary deficiency
Outstanding Balance in account based on the drawing power calculated from stock statements older than 3 months would be deemed as irregular & if such irregular drawing are permitted for a period of 90 days, account needs to be classified as NPA. Non-renewal/ Non-regularisation of regular/ adhoc limit within 180 days from the due date.
Vipul K. Choksi, FCA

Exceptions / Clarifications ...

Advances against term deposits, NSCs, IVPs, KVPs and Life Insurance Policies need not be treated as NPAs, till security cover is sufficient to cover outstanding balance. Income to be recognised subject to availability of margin. Advance against gold ornaments Government securities not exempt. /

Vipul K. Choksi, FCA

Exceptions / Clarifications
Central Government guaranteed advance to be classified as NPA only if Government repudiates the guarantee when invoked. Classification Qua Borrower
All facilities granted to a borrower shall be treated as NPA & not only that facility which has become irregular. Exception: Credit facility to Primary Agricultural Credit Society (PACS) and Farmers Service Societies (FSS) under on lending arrangement.
Vipul K. Choksi, FCA

Exceptions / Clarifications
Consortium Advances Member banks shall classify the accounts according to their own record of recovery. Bank needs to arrange to get their share of recovery or obtain an express consent from the Lead Bank.

Vipul K. Choksi, FCA

Exceptions / Clarifications
Straightaway Classification
Where realisable value of security is less than 50% of the value assessed, account to be straightaway classified as Doubtful Asset. Where realisable value of security is less than 10% of outstanding balance, account to be straightaway classified as Loss Asset.

Vipul K. Choksi, FCA

Exceptions / Clarifications
Valuation of Securities
In respect of NPAs with the balance of Rs. 5.00 crores & above, bank needs to formulate policy for annual stock audit by external agencies & in respect of immovable properties, valuation to be carried out once in 3 years by approved valuer.

Vipul K. Choksi, FCA

Exceptions / Clarifications
Solitary Credit Entry
Care should be taken that a solitary or few credits in the account made at/near the balance sheet date extinguishing the overdue interest/principal is not the only criteria for classifying the asset as standard.

Vipul K. Choksi, FCA

Exceptions / Clarifications
Regularisation of Account
Account need not be classified as NPA if account has been regularised by the date of Balance sheet by payment of overdue through genuine sources & not by sanction of additional facility or transfer of funds between accounts.

Vipul K. Choksi, FCA

Classification - Projects under Implementation

'Project Loan' would mean any term loan which has been extended for the purpose of setting up of an economic venture. Banks should fix a Date of Commencement of Commercial Operations (DCCO) for all project loans at the time of sanction of the loan / financial closure. For all projects financed by the FIs/ banks after 28th May, 2002, the date of completion of the project should be clearly spelt out at the time of financial closure of the project.
These asset classification norms would apply to the project loans before commencement of commercial operations.
Vipul K. Choksi, FCA

Classification - Projects under Implementation

Any change in the repayment schedule of a project loan due to increase in the project outlay would not be treated as restructuring if :
The increase in scope and size of the project takes place before commencement of commercial operations of the existing project. The rise in cost excluding any cost-overrun in respect of the original project is 25% or more of the original outlay. The bank re-assesses the viability of the project before approving the enhancement of scope and fixing a fresh DCCP. On re-rating, (if already rated) the new rating is not below the previous rating by more than one notch.
Vipul K. Choksi, FCA

Classification - Projects under Implementation

Infrastructure Sector
Classify as NPA any time before commencement of commercial operations, if interest/ installment is 90 days overdue unless restructured and eligible to be classified as standard. Classify as NPA if its fails to commence commercial operations within two years from the original DCCO unless restructured and eligible to be classified a standard.

Vipul K. Choksi, FCA

Classification - Projects under Implementation

Permissible limit for extension of date of commencement of commercial operations.
Court cases : another two years beyond the extended period of two years Other reason: another one year beyond the extended period of two years. Other conditions: Application for restructuring should be receive before the expiry of period of two years from original DCCO. If there is a moratorium, bank should not recognise income beyond two years from original DCCO. Bank should maintain necessary provision as long as these are standard assets.
Vipul K. Choksi, FCA

Classification - Projects under Implementation

Non Infrastructure Sector
Classify as NPA any time before commencement of commercial operations, if interest/ installment is 90 days overdue unless restructured and eligible to be classified as standard. Classify as NPA if its fails to commence commercial operations within six months from the original DCCO unless restructured and eligible to be classified a standard.

Vipul K. Choksi, FCA

Classification - Projects under Implementation

Permissible limit for extension of date of commencement of commercial operations.
Other reason: another one year beyond the extended period of six months.

Other conditions:
Application for restructuring should be receive before the expiry of period of six months from original DCCO. If there is a moratorium, bank should not recognise income beyond six months from original DCCO. Bank should maintain necessary provision as long as these are standard assets.

Vipul K. Choksi, FCA

Income Recognition
For NPA accounts income should be recognised on realisation basis. When an account becomes non-performing, unrealised interest of the previous periods should be reversed or provided. Interest income on additional finance in NPA account should be recognised on cash basis. In project loan, funding of interest in respect of NPA if recognised as income, should be fully provided. If interest due is converted into equity or any other instrument, income recognised should be fully provided.
Vipul K. Choksi, FCA

Income Recognition
Adjustment of Recoveries - Priority
Unrealised Expenses Unrealised Interest Amount of Principal Outstanding Clarification vide Master Circular - in the absence of clear agreement between the Bank and the Borrower, an appropriate policy to be followed in uniform and consistent manner.
Vipul K. Choksi, FCA

Classification Norms
Standard Asset
The account is not non-performing.

Sub-Standard Asset
A sub standard Asset is one which has remained NPA for a period of less than or equal to 12 months.

Loss Assets
These are accounts, identified by the bank or internal or external auditors or by RBI Inspectors as wholly irrecoverable but the amount for which has not been written off.
Vipul K. Choksi, FCA

Classification Norms
Doubtful Asset - Three Categories Category Doubtful - I Period up to One Year

Doubtful II One to Three Years Doubtful - III More than Three Years

Vipul K. Choksi, FCA

Provisioning Norms
Standard Asset
Agricultural and SMEs Sectors .25% Commercial Real Estate (CRE) Section 1% Others .40% Vide circular dated 23rd December 2010, provision on housing loan accounts has been increased to 2% with immediate effect.

Sub-standard Asset
10% of total outstanding 20% of total outstanding if loan is unsecured
Vipul K. Choksi, FCA

Provisioning Norms
Doubtful Assets: Period Provision Up to 1 year 1to 3 years More than 3 years
(Secured + Unsecured) 20% + 100% 30% + 100% 100% + 100%

Loss Asset: 100% should be provided for Banks should have total provisioning coverage ratio of not less than 70%.
Vipul K. Choksi, FCA

Provisioning for Country Risk

In respect of a country where its net funded exposure is 1% of its total exposure

Risk Category Insignificant Low Moderate High Very High Restricted Off-Credit

ECGC classification A1 A2 B1 B2 C1 C2 D

Provisioning requirement (%) 0.25 0.25 5 20 25 100 100

Vipul K. Choksi, FCA

Lower provision in respect of short term exposure

Provisioning Norms
Provision Under Special Circumstances
Advance under rehabilitation programme approved by BIFR / Institutions, Provision should be continued to be made on existing facilities. Additional facilities no provision for a period of one year. In case of advances guaranteed by CGTSI/ECGC, Provision should be made only for balance in excess of the amount guaranteed by these corporations.

Vipul K. Choksi, FCA

Some other aspects

Take out Finance Post-shipment supplier credit Export Project Finance

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

Restructuring divided in following four categories;
i. Industrial Units.

ii. Industrial Units under CDR Mechanism iii. SMEs iv. All other advances.

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

Eligibility
Any account classified as standard, sub standard or doubtful. Restructuring cannot be done retrospectively and usual asset classification norms would continue to apply. Restructuring should be subject to customer agreeing to terms and conditions. Financial viability should be established. Borrowers indulging in frauds and malfeasance or in eligible. BIFR cases eligible for restructuring subject to approval from BIFR.

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

Asset Classification Norms Restructuring of accounts could take place in following stages:
Before commencement of commercial production After commencement of commercial production / operation but before the asset has been classified as Sub Standard. After the commencement of commercial production / operation but after the asset has been classified as Sub Standard or doubtful.

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

Asset Classification Norms (Contd)
Standard Asset would get reclassified as sub standard and account which is already NPA would continue to have the same classification. Additional finance would be treated as standard upto a period of one year. All restructured accounts, classified as NPA upon restructuring would be eligible for upgradation after observation of satisfactory performance for the period of one year.

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

Provisioning Norms
Total provision required would be normal provision plus provision in lieu of diminution in fair value of advances. Diminution in fair value would be required to be recomputed on each balance sheet date. Banks have option of notionally computing the diminution in fair value and providing at 5% in case of all restructured accounts where the total dues to bank is less than one crore.

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

Special Regulatory Treatment for asset classification.
Not available to following categories of advances:
Consumer and personnel advances Advances is classified as capital market exposure Advances classified as commercial real estate exposure.
I.

Incentive for quick implementation of package The asset classification status may be restored if the approved package is implemented :
Within in 120 days from the date of approval under CDR Within 90 days from the date of receipt of application by Bank in other cases.
Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

II. Asset classification benefits
a. Standard advance will not be reclassified as sub standard upon restructuring if following conditions are satisfied.
i. Dues of the bank are fully secured by tangible security (except SSI borrower with outstanding upto Rs.25 lacs & infrastructure projects)

ii. Unit becomes viable in 10 years, if it is engaged in infrastructure activities and in 7 years in case of other units.

Vipul K. Choksi, FCA

Guidelines on Restructuring of Advances

iii. Repayment period including moratorium does not exceed 15 and 10 years for infrastructure and other projects respectively ( 10 years ceiling wont apply to restructured hosing loan accounts) iv. Promoters sacrifice and additional funds brought by them should be a minimum of 15% of banks sacrifice (Ref RBI Circular dated 7th October 2010) v. Personal guarantee is offered by promoters. vi. The restructuring is not repeated restructuring

b. During the specified period the asset classification of sub standard / doubtful accounts will not deteriorate, if satisfactory performance is demonstrated during the specified period.
Vipul K. Choksi, FCA

Agricultural Debt Waiver Scheme

Prudential norms. Agricultural debt waiver and debt relief scheme 2008.
Amount eligible for waiver to be transferred to a separate account named Amount receivable from Government of India under Agricultural Debt Waiver Scheme 2008. Banks neither to claim nor recover from the farmer, interest in excess of the principal amount, penal interest, legal charges, miscellaneous charges etc for the assets which are NPA at the time of restructuring.

Vipul K. Choksi, FCA

Agricultural Debt Waiver Scheme

The balance may be treated as performing asset provided adequate provision is made for loss in present value term. Assumptions for receipt of money from Government of India. a) 32% by 30th September 2008. b) 19% by 31st July 2009 c) 39% by July 2010 d) 10% by July 2011. (Since Government of India has decided to pay interest on balance installments, loss in PV term need not be provided).
Discount rate 9.56%.
Vipul K. Choksi, FCA

Agricultural Debt Waiver Scheme

Provision required under the current norms of standard asset need not be provided. Provision already held in NPA account may be reckoned for meeting the required provision on PV basis. Prudential provision more than the amount of provision may be reversed in the proportion of 32%, 19%, 39% and 10% during the year ended, March 2009, 2010, 2011 and 2012 only after the installments for the relative year have been received. In case of rejection of claims normal prudential norms be applied Under the Scheme, in case of other farmers 75% of the amount should be released in three installments of 30th September 2008, 31st March 2009 and 30th June 2009.
Vipul K. Choksi, FCA

Agricultural Debt Waiver Scheme

Vide circular dated June 25, 2009, there was a relaxation permitting farmers to pay the amount in single installment by 30th June 2009. Vide circular dated August 31, 2009, this date extended to 31st December 2009. Banks allowed to recover less than 75% of the amount provided they dont claim difference from Govt. Farmers relevant account may be treated as standard provided.
i) ii) Adequate provision is made by the bank for the loss in PV terms. The farmers have given undertaking to pay their share and pay them share of the settlement within one month of due date.

Fresh Agricultural loan be treated as standard.

Vipul K. Choksi, FCA

Thank you!